Unpacking compliance, security and AI.
Our DPOs and CISOs regularly share their take on regulatory and technical news here: new CNPD guidelines, notable sanctions, incident lessons learned, evolutions on the AI Act, NIS 2 and DORA. To go beyond the press release.
29 articles found · #cssf
CSSF 25/892: quantifying ICT incident costs — adopt 3‑2‑1‑1‑0 immutable backups
Since 28/05/2025, the CSSF requires annual aggregated estimation of costs/losses from major ICT incidents (JC 2024 34). Immutable, isolated 3‑2‑1‑1‑0 backups cut financial impact and provide the required evidence.
Authentication logs: key evidence (French Conseil d’État, 26/06/2023) and NIS 2
The Conseil d’État validated purpose‑bound access to authentication logs. To meet NIS 2 (24h) and CSSF expectations, a Logging + SIEM + Forensics setup is now essential.
DORA Art. 28: Register of Information — CSSF expectations for 2026
The CSSF opened eDesk and set a DORA Register of Information submission window from 11 February to 31 March 2026. Content is standardized by ITS (EU) 2024/2956 and subject to strict validation rules.
Council of State upholds CNIL authorisation for HDH: cloud impact and proof of compliance
On 20/03/2026, France’s Council of State upheld CNIL’s authorisation for the Health Data Hub hosted on Azure in France. Key takeaway: use CSPM to evidence compliance with GDPR, NIS 2 and CSSF 22/806.
NIS 2 vs DORA in Luxembourg: notify in 24 h or 4 h?
Verifiable fact: CSSF Circular 25/893 (27/05/2025) aligns DORA reporting with a first notification “within 4 hours” after classification. NIS 2 requires a preliminary alert “within 24 hours.” Key issue: who to notify, when, and against which clock in Luxembourg.
CSSF 25/903: Support PSF — the inventory/CMDB as key evidence
CSSF 25/903 strengthens 24/850 and requires structured evidence on support PSF ICT organization. An automated inventory/CMDB becomes central to trace assets, dependencies and controls, and to meet NIS 2 obligations.
European Commission: Europa.eu breach — how a CSPM prevents the next one
On March 27, 2026, the European Commission confirmed data exfiltration from its cloud hosting Europa.eu. Here’s how a CSPM evidences compliance (GDPR Art. 32, CSSF 22/806) and prevents a repeat.
CSSF 26/906: strengthened governance and risk — an ISO 27001 ISMS to evidence NIS 2
CSSF 26/906 tightens governance and risk for payment/e-money institutions, with compliance due by 30 June 2026. A certified ISO 27001 ISMS operationalizes these requirements and NIS 2 Article 21.
CSSF 26/904: stronger ICT evidence — inventory/CMDB becomes essential
CSSF Circular 26/904 tightens investment firms’ self‑assessment by requiring concrete evidence on ICT organization. An automated inventory and a relational CMDB are the most reliable way to demonstrate effective control.
CSSF 26/914: AMLA supervision — the ICT inventory becomes vital
CSSF 26/914 identifies entities eligible for AMLA’s direct supervision. Governance and traceability tighten: a reliable, continuous inventory/CMDB is now essential to evidence NIS 2/ISO 27001 controls.
CSSF 25/893: reporting a major incident in 4h with EDR/XDR
CSSF Circular 25/893 formalizes DORA reporting for major ICT incidents and significant cyber threats. A well‑tuned EDR/XDR stack speeds up detection, classification, and 4h/72h/1‑month notifications.
Processors: CNPD (Art. 28 GDPR) vs CSSF 22/806 — two contractual layers
CSSF’s 9 April 2025 update widens the gap with the CNPD/EDPB approach: beyond the GDPR DPA, financial entities must add access/audit clauses, prudential notifications, reversibility, and cloud-specific requirements.